Answer To Show Cause Order

REPUBLIC OF THE PHILIPPINES
Department Of Transportation
Land Transportation Regulatory Board
Regional Office V
ANDREW E. DONCILLO, CASE NO. CO-EB-2024-04-088

Respondent Operator
x---------------------------------------------x
ANSWER TO SHOW CAUSE ORDER
COMES NOW, Respondent, and unto this Honorable Office most

respectfully avers that:
1. I, Andrew E. Doncillo, is the operator of UV Express under

LTFRB Franchise No. 123456 with authorized route of Legazpi to
Naga, more particularly described as follows;
No Make Motor No. Chassis No. Plate
No.
1 TOYOTA/GRANDIA 7D23- TG475L- ATY-
100562 800019 226
2. That the operator has been a member in good standing over the
years of operation, being the first franchisee in the said route, with
no record of apprehension or violation with respect to with terms
and conditions of the franchise granted, as well as the rules and
regulations of the Land Transportation Franchising and Regulatory
Board (LTFRB) and all other issuances and orders of the said
Office;
3. That sometime in April 15, 2024, herein respondent together with

his friends are travelling to Matnog, Sorsogon to attend a barrio
fiesta.
4. That, at around 9:00 AM, the herein respondent was made to stop
by LTO Officers for checkpoint in Putiao, Pilar Sorsogon for
inspection.
5. That, upon inspection all necessary documents such as the Driver’s

License, Vehicle Certificate of Registration and Official Receipt
were properly presented and everything is found in order.
6. That, herein respondent specifically deny the allegation in

paragraph 6, maintaining that the vehicle was not rented but is
being privately use by herein respondent as vehicle going to
Matnog Sorsogon for personal affair,
7. Further, herein respondent and PUV operator and Leon Mangubat,

(one of the passenger on the said incident), are close friends.
Consequently, as debt of gratitude and pakikisama for their years
of friendship, herein respondent drove for Leon Mangubat going
to Matnog to attend a fiesta celebration without any monetary
consideration.
8. Further alleged that, Leon Mangubat, the passenger does not

comprehend the question asked by the LTO officer due to noise by
the passing vehicles and the ongoing procession, just nod and
smile as courtesy. (Passengers affidavit is herein attached as Annex
1)
9. That in response to alleged violation for failure to present a special

permit, herein respondent deemed it not necessary since the
respondent is not ferrying passenger along the way to their
destination. Rule IV of JAO No. 2014-01 provides:
A PUV operating outside of its approved route or area
without a prior permit from the Board or outside the
exceptions provided under existing memorandum
circulars;
10.That, herein respondent maintains that the subject vehicle is
not operating as public utility vehicle but for personal and
private use. Hence, doesn’t violate the abovementioned rules.
PRAYER
WHEREFORE, in the light of the foregoing, it is most respectfully

prayed of this Honorable Office that the CASE NO. CO-EB-2024-
04-088 be dismissed for lack merit.
That the UV Van with Plate No. ATY-226 and LTFRB Franchise
No. 123456 be released
That a counterclaim of 200,000 pesos as actual damages for loss of

profit be granted.
Other reliefs just and equitable under the premises are likewise
prayed for.
Legazpi City, 05 May, 2024.

VERIFICATION AND CERTIFICATION OF NON-FORUM
SHOPPING
I, ANDREW E. DONCILLO, of legal age, Filipino, and a resident of 25C

Marquez St. Brgy Ilawod (Brgy. 15), Legazpi City, Albay, after having been
duly sworn, depose and state:
1. That I am the Respondent in the forgoing Answer in the above-
captioned case;
2. That I caused the preparation of the Answer, which I have fully read
and understood;
3. That all factual allegations and denials contained in the said Answer
are true and correct of my own personal knowledge and belief, as well
as true and correct on the basis of authentic documents and records on
my possession;
4. That I have not commenced any action or filed any claim involving
the same issues in any court, tribunal, or quasi-judicial agencies;
5. That to the best of my knowledge no such action or proceeding is
pending in any court, tribunal or quasi-judicial agency;
6. That if I should hereafter learn that any other similar action or claim
has been filed or is pending, I shall report that fact within five (5) days
from knowledge thereof to this Honorable Court.
IN WITNESS WHEREOF, I have hereunto set my hands this 5 th day of

May 2024 in Brgy 4 Sagpon, Legazpi City, Philippines.
ANDREW E. DONCILLO
Affiant
Republic of the Philippines )

City of Legazpi ) S.S
SUBSCRIBED AND SWORN TO before me this 5th day of May

2024 in Brgy 4 Sagpon, Legazpi City, Philippines, by the above-named
affiant who has satisfactory proven to me her identity through her TIN
065-678-321-000, to be the same person who presented and personally
signed before me and attested that the contents thereof are true and
correct; and she voluntarily executed the same.
ATTY. LARRA S. DEJUMO

NOTARY PUBLIC Case No. 2023/09-045
VALID UNTIL DECEMBER 31, 2025
Doc. No. ______: IBP No. 211083 05/15/2024
Page No. ______: PTR No. 1277018 01/03/2024
Book No. ______: Roll No. 89760 Sorsogon
Series of 2024. MCLE – Admitted to the Bar 2023

Answer To Show Cause Order

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REPUBLIC OF THE PHILIPPINES

ANDREW E. DONCILLO, CASE NO. CO-EB-2024-04-088

ANSWER TO SHOW CAUSE ORDER

COMES NOW, Respondent, and unto this Honorable Office most

1. I, Andrew E. Doncillo, is the operator of UV Express under

3. That sometime in April 15, 2024, herein respondent together with

5. That, upon inspection all necessary documents such as the Driver’s

6. That, herein respondent specifically deny the allegation in

7. Further, herein respondent and PUV operator and Leon Mangubat,

8. Further alleged that, Leon Mangubat, the passenger does not

9. That in response to alleged violation for failure to present a special

WHEREFORE, in the light of the foregoing, it is most respectfully

That a counterclaim of 200,000 pesos as actual damages for loss of

Legazpi City, 05 May, 2024.

I, ANDREW E. DONCILLO, of legal age, Filipino, and a resident of 25C

IN WITNESS WHEREOF, I have hereunto set my hands this 5 th day of

Republic of the Philippines )

SUBSCRIBED AND SWORN TO before me this 5th day of May

ATTY. LARRA S. DEJUMO

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